Case Summary (G.R. No. 132988)
Parties Involved
- Plaintiffs/Appellants: Victoria T. de Winkleman and C. L. Winkleman
- Defendant/Appellant: Filemon Veluz
- Owner of the Leased Property: Segunda Abuel
Case Background
Upon the purchase of the property, de Winkleman believed she could terminate Veluz's lease and sought legal remedy to compel Veluz to deliver possession of her property. Veluz, countering this claim, requested to stay on the property during the agricultural year, sought damages, and argued that the case fell under forcible entry and detainer jurisdiction, which would belong to a justice of the peace court instead of the Court of First Instance.
Trial Court's Decision
The trial court partly favored de Winkleman but awarded the property's fruits to Veluz and declared the lease terminated. This decision was contested by both parties, with de Winkleman disputing the award to Veluz, and Veluz challenging the court's jurisdiction.
Jurisdiction Analysis
The Supreme Court found Veluz’s contention regarding the lower court's lack of jurisdiction invalid. The case's essence was not merely about ejectment, but rather whether de Winkleman had the right to terminate the lease after her purchase. Therefore, the Court of First Instance had the proper authority to adjudicate the matter.
Application of Civil Code
The pivotal question was whether de Winkleman could invoke Article 1571 of the Civil Code to terminate Veluz’s lease. Article 1571 states that a purchaser is entitled to terminate any existing lease unless otherwise stipulated. The court examined two critical exceptions to this article: any contrary stipulation between seller and buyer and the status of the purchaser as a third party with respect to the Mortgage Law.
Knowledge of the Lease
The court underscored that de Winkleman was aware of the lease's terms before purchasing the property. Though the stipulation to respect the lease wasn't included explicitly in the deed, the law does not require such terms to be recorded, provided the buyer has actual knowledge. De Winkleman's awareness was adequate for the lease to be impliedly part of the sale agreement.
Registration of Lease
The court further elaborated that since Veluz was the lessee under a contract exceeding six years, the lease constituted a real right, typically subject to registration under the Mortgage Law. Although the lease was not registered due to the lack of prior registration of the property, de Winkleman's knowledge of the lease conditions prior to pu
...continue readingCase Syllabus (G.R. No. 132988)
Case Background
- Segunda Abuel owned two parcels of land located in the Province of Tayabas.
- On February 20, 1918, she leased these lands to Filemon Veluz for a term of nine years, with a stipulation that the lease would remain in effect if the lands were sold.
- In January 1919, Victoria T. de Winkleman expressed interest in purchasing one of the parcels and conducted an investigation, discovering the existing lease and reading the lease contract herself.
- On January 11, 1919, she purchased one of the parcels from Segunda Abuel, but the deed of sale did not mention the lease contract.
- The lands were not registered in the registry of deeds, meaning neither the lease nor the sale was recorded.
- Upon attempting to take possession of the land, de Winkleman faced refusal from Veluz, leading her to initiate legal action.
Legal Proceedings
- Victoria T. de Winkleman filed a complaint against Filemon Veluz, seeking to compel him to deliver the property along with its fruits, or, in the absence of the fruits, to pay their value amounting to P1,500 plus costs.
- Veluz raised several defenses, requesting to be absolved from the complaint and asserting that if the lease was terminated, he should be allowed to remain on the land for the agricultural year and seek damages and return of advance rent from the lessor, Segunda Abuel.
- The trial court ruled partly in favor of de Winkleman but awarded the fruits of the property to Veluz and declared the lease terminated.
Jurisdictional Issues
- Veluz contended that the ca